Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Revision u/s 263 - large share premium received - valuation of shares and the applicability of Section 56(2)(viib) - The Tribunal found that the PCIT's order was erroneous as it did not properly consider the assessee's provided documentation and valuation report under Rule 11UA of the Income Tax Rules. The Tribunal concluded that the original assessment order by the Assessing Officer (AO) was not erroneous, and thus, the exercise of power u/s 263 by the PCIT was incorrect.
Revision u/s 263 - large share premium received - valuation of shares and the applicability of Section 56(2)(viib) - The Tribunal found that the PCIT's order was erroneous as it did not properly consider the assessee's provided documentation and valuation report under Rule 11UA of the Income Tax Rules. The Tribunal concluded that the original assessment order by the Assessing Officer (AO) was not erroneous, and thus, the exercise of power u/s 263 by the PCIT was incorrect.
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